What Recent Executive Orders and the Review of Federal Financial Assistance Means for You
**This is a comprehensive blog that covers the key developments, implications, and strategies for grant seekers navigating the landscape of federal financial assistance under the new Administration. Updates to this blog will continue to be made as the situation develops. Blog last updated 2/7/25 at 9:56 am ET**
The federal grant landscape was upended this week by the release of the Memorandum M-25-13, a sweeping directive that temporarily halted financial assistance programs for a review process aligned with the new Presidential Administration’s policy priorities. While the Administration later rescinded with memorandum M-25-14, grant seekers across all sectors - including public agencies and nonprofits – still face a multitude of questions and uncertainty around the effect of recent Executive Orders on federal funding opportunities.
A Timeline of Key Events
- January 27, 2025 – The new Administration released Memorandum M-25-13, requiring federal agencies to halt the obligation, disbursement, and administration of financial assistance programs after 5:00PM on January 28, 2025.
- January 28, 2025 – A federal judge temporarily blocked the portion of the memorandum affecting "open grants," allowing already awarded funds to continue flowing until the court hearing on February 3, 2025.
- January 29, 2025 – The federal Office of Management and Budget (OMB) released Memorandum M-25-14, formally rescinding its previous memo and allowing federal financial assistance to flow to recipients. The Administration reaffirmed its intentions to complete full funding reviews of all agencies and departments. Funding pauses put into effect by other Executive Orders remained in effect.
- February 3. 2025 – U.S. District Court keeps temporary block on federal funding freeze in place, indicating recission of M-25-13 did not resolve the matters before the Court.
- February 5, 2025 – The newly appointed Attorney General ordered a temporary pause in federal funding flowing from the Department of Justice to sanctuary cities. The stated purpose of the pause is to review current agreements and ensure they do not violate the law. A similar move during the previous Trump Presidential Administration was largely unsuccessful when reviewed by the courts.
- February 6, 2025 as of 12am ET – Grants.gov servers were taken down. The agency claims that improvements are being made to boost the system. According to the NIH, Grants.gov will be back online and operational on February 10th at 12:01AM EST.
- As of February 6, 2025 at 11am ET – Notwithstanding the previous note, Grants.gov appears to be operational.
- February 10, 2025 – Federal agencies must submit reports to the Office of Management and Budget (OMB) detailing funding programs that may conflict with executive orders or Administration policies.
- February 10, 2025, and Beyond – The Administration is expected to release further details on targeted program cuts or modifications based on agency reports.
- March 14, 2025 – The Continuing Resolution keeping the government funded expires, requiring Congressional action to pass a new budget and potentially influencing the future of grant programs.
What was inside Memorandum M-25-13?
The stated goal of Memorandum M-25-13 was to temporarily pause federal funding distribution to ensure taxpayer dollars are used to advance Administration priorities. This includes:
- Strengthening national security
- Reducing inflation
- Promoting energy independence and U.S.-based manufacturing
- Ending Diversity, Equity, and Inclusion (DEI) initiatives
- Eliminating support for green energy programs
Federal agencies were provided with a spreadsheet by the OMB to designate which Federal financial assistance programs, projects, and activities may conflict with recent executive orders. They were further tasked with (1) assigning a “senior political appointee” to ensure all funding conforms to new administrative priorities, and (2) reviewing pending awards of Federal financial assistance to ensure compliance. In total, this review would encompass more than $3 trillion dollars across 2,600 funding programs.
According to the memo, documentation must be submitted to the Administration by February 10, 2025. The OMB and senior political appointees of the new Administration were expected to review this information and make recommendations on programs that are inconsistent with Administration priorities in the weeks that followed.
How does Memorandum M-25-14 change things?
The new memo issued by the OMB rescinds its predecessor and encourages those with questions on the President’s Executive Orders to contact their General Counsel. This retraction allows federal financial assistance to continue flowing to recipients.
What happens next?
Shortly after the original memo was rescinded, Matthew Vaeth, acting director of the OMB, clarified that federal agencies should “to the extent permissible under applicable law” continue their pause on all activities related to obligation or disbursement of funding that may be impacted by the Administration’s other executive orders.
White House Press Secretary, Karoline Leavitt, further clarified the Administration’s plans for reviews of the federal government’s 2,600 funding programs remain “in full force” and that more executive action to reduce federal funding should be expected. No further clarification on the OMB’s review – including timeline, expectations, or participating individuals - has been made public at this time.
What does this mean for Grant Seekers?
While the impacts of executive action around grant funding continue to solidify, the broad scope of this conflict creates immediate challenges for those relying on federal grant funding. Here are the key takeaways:
- Grants Can Continue (For Now)
Memorandum M-25-14 effectively ended the temporary hold on federal financial assistance. This means that existing grant program monies that have already been obligated should continue to be disbursed.
- New Grants Remain in Limbo
The OMB’s recommendation to pause distribution and obligation of funding means that all pending or currently active Notice of Funding Opportunities (NOFOs) should still expect to be placed under review and could be modified or withdrawn to align with the Administration’s goals. The Administration is expected to continue in its fact-finding mode, collecting data on more than 2,600 programs, including school meal initiatives, foreign aid, and veteran reintegration programs.
- Discretionary Programs Are Most at Risk
Grant programs that allow federal agencies significant discretion in funding priority decisions are the most vulnerable. However, statutory grant programs—those written into law with clear funding priority parameters—are more insulated from sudden cuts or modifications.
- Legal and Political Uncertainty Continues
Several lawsuits have already been filed by states, nonprofits, and active grant award recipients challenging the legality of the President’s original memorandum. While the overriding memorandum provides some relief, the long-term outlook depends on future judicial rulings and potential Congressional intervention.
Looking Ahead: Strategies for Grant Seekers
Despite the uncertainty, there are still ways to navigate the evolving grant landscape effectively:
- Explore Alternative Funding Sources
- State & Local-Sourced Grants: Many states and municipalities administer their own grant programs that may not be affected by federal actions.
- Private & Corporate Foundations: Nonprofit and corporate philanthropy organizations may fill some funding gaps. Private funders have a history of stepping up in situations where public funding falls short or is temporarily jeopardized (i.e. most recently with the global Coronavirus pandemic).
- Industry Partnerships: Businesses may seek public-private partnerships to support innovation and development projects.
- Stay Informed and Agile
- Monitor updates from the OMB, federal agencies, and Grants Office to track funding opportunities and potential reinstatements.
- Be ready to pivot if a target grant program’s priorities shift away from previous competitions—consider adjusting proposals to align with Administration priorities where feasible. Be prepared with back-up grant opportunities your organization is also willing to consider for pursuit.
- Advocate and Engage with Policymakers
- Contact Congressional representatives to express concerns about program cuts and advocate for continued funding in critical areas.
- Participate in industry coalitions or trade associations that may have a voice in lobbying efforts.
Final Thoughts: Adaptation is Key
While these executive actions have created significant disruption, it does not signal the end of federal grant programs. History shows that grant funding remains a core mechanism for public investment, and bipartisan Congressional support for key initiatives will ensure many essential programs continue.
At Grants Office, LLC, we are committed to guiding grant seekers through this complex and rapidly changing environment. Whether it’s identifying alternative funding sources, interpreting new policies, or adjusting grant strategies, we are here to help.
Stay connected with us for ongoing updates and insights into the evolving federal grant landscape by joining our free Community of Grantseekers.
View and download our recent Grantscast and additional resources:
The Pause on Federal Funding: Context and Proactive Strategies for the Months Ahead
Making Sense of Recent Executive Orders and the Impact on Federal Grant Funding
The latest in a flurry of Executive Orders has hit home for grant-funded agencies across the country. Despite the rescission of M-25-13, which placed a temporary pause on "all activities related to obligation or disbursement of all Federal financial assistance," there are plenty of questions surrounding the future of federal funding. All federal agencies are expected to submit reports to the Office of Management and Budget (OMB) by February 10th detailing all programs, projects, or activities that will be impacted by recent Executive Orders.
Two of Grants Office's most experienced executives discuss the implications for federal grants in the near term, and proactive steps government and nonprofit leaders can take to ensure they are ready to make the most of federal grant opportunities in 2025 and 2026.
We will discuss:
- What happened with OMB Memorandum M-25-13
- The current review process underway by federal agencies to comply with recently issued Executive Orders
- What we expect to happen after the pending February 10 reporting deadline and upcoming federal budget process
- Strategies for proactive grantseekers to capture more federal funding over the next two years
With the new administration in place and significant changes afoot to both the structure and function of the federal government, complacency is not an option for grantseekers. It’s essential that we stay attentive to the shifting funding landscape. As always, Grants Office will be here to help you navigate it. We anticipate a lot of interest in this topic from our grantseeking community.
View and download our recent Grantscast and additional resources:
The Pause on Federal Funding: Context and Proactive Strategies for the Months Ahead